To monitor the implementation of the BEPS project globally, we call on the OECD to develop an inclusive framework by early 2016 with the involvement of interested non-G20 countries and jurisdictions which commit to implement the BEPS project, including developing economies, on an equal footing.”

*The OECD Centres in Berlin, Mexico, Tokyo and Washington organize lectures, seminars and other events to disseminate the Organization’s work, often helping to bridge language gaps. *The OECD Observer, the Organization’s public magazine, also keeps readers up to date on key issues related to OECD work. 13.

It outlines on the major Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project including in their treaties: (i) the combined approach of an LOB and PPT rule The OECD BEPS Action 6 report contains a principal pur- pose test rule (PPT rule ) for the purpose of combating abuse of tax treaties. This PPT rule is also Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project including in their treaties: (i) the combined approach of an LOB and PPT rule 2 May 2019 And the OECD, as part of Action 6 of the BEPS project, recommended measures to tackle treaty abuse, including the incorporation of a 'principal 26 Jul 2019 Action 6 of BEPS introduced the principal purpose test (PPT) as one of the In the OECD Model, the benefit under tax treaty is found in the 7 Aug 2020 The PPT is included in Article 7 (Prevention of Treaty. Abuse) of the MLI. Where both countries which are party to a double tax treaty (Contracting. (BEPS)9.

CFC. CTA. GAAR. HFD. LOB. MLI. OECD. PPT. WAA. The Anti Tax Avoidance Directive. Base Erosion and Profit Shifting. Controlled OECD (BEPS 6 & 15): Åtgärder för att bekämpa miss. i) en kombination av LOB- och PPT-regler, ii) endast en PPT regel eller iii) genom en staternas skatteavtal föranledda av OECD:s så kallade BEPS-projekt. kallat Principal Purpose Test (PPT), det vill säga att en avtalsförmån Den 22 maj 2015 publicerade OECD ett reviderat diskussionsutkast anti-missbruksregeln som baseras på ett principal purpose test (PPT), av C Enea · 2016 — missbruk av skatteavtal, tolkning av skatteavtal, BEPS-projektet, Action 6, OECD, limitation of benefit, LOB, Principal Purpose Test, PPT av J Svensson · 2019 — Se även OECD:s Update on Tax Certainty, 2018.

4 The BEPS Project has been … • 2-year time-bound Fast-pace • OECD and G20 countries working together on an equal footing • 14 Developing Countries, ATAF, CREDAF and CIAT participating directly • Other 60 Developing Countries participating via Regional Networks in Asia, Africa, Latin America and Eurasia Inclusive • 23 Discussion Draft published • 12,000 pages of comments received

Rapporten innehåller en minimumstandard och förslag på regler som syftar OECD and G20 members. In order to become a BEPS Associate, a participant must to commit to implementing the four BEPS minimum standards on harmful tax practices (BEPS Action 5), tax treaty abuse (BEPS Action 6), Country -by country reporting (BEPS Action 13) and cross-border tax dispute resolution (BEPS Action 14).

4 The BEPS Project has been … • 2-year time-bound Fast-pace • OECD and G20 countries working together on an equal footing • 14 Developing Countries, ATAF, CREDAF and CIAT participating directly • Other 60 Developing Countries participating via Regional Networks in Asia, Africa, Latin America and Eurasia Inclusive • 23 Discussion Draft published • 12,000 pages of comments received

The PPT rule is applicable when ‘it is reasonable to conclude’ that obtaining a benefit is one of the principal purposes of an arrangement (the reasonableness test). 2016. OECD and G20 countries have also agreed to continue to work together to ensure a consistent and co-ordinated implementation of the BEPS recommendations. Globalisation requires that global solutions and a global dialogue be established which go beyond OECD and G20 countries.

Se hela listan på skatteverket.se 2020-08-18 · OECD Oslo Dialogue Tax crimes, corruption, money laundering and other illicit flows threaten the strategic, political and economic interests of countries. Illicit financial flows are of concern to all countries, but particularly to developing countries, as they strip resources that could finance their long-term development. 2015-10-06 · Senior members from the OECD's Centre for Tax Policy and Administration (CTPA) commented on the final outputs of the OECD/G20 Base Erosion and Project Shifting Project, including the next steps and the involvement of developing countries.
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Erosion and Action 6 Prevention of tax treaty abuse BEPS Action 6 addresses treaty shopping through treaty provisions whose adoption forms part of a minimum standard that those countries have given the OECD their choices of PPT or LOB for each bilateral tax treaty they are party to. Depending on what the other party to each.

It also includes specific rules and recommendations to address other forms of treaty abuse. OECD’s BEPS initiative—Deloitte’s sixth annual survey The purpose of Deloitte’s 2019 survey was to gauge multinationals’ views on the progress of the implementation of the BEPS project recommendations and their views on consequential developments within their organizations given the changing tax landscape. The OECD BEPS Action 6 report contains a PPT rule 61 x See BEPS Action 6, above n. 1.
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signerat OECD:s multilaterala instrument för att implementera BEPS-åtgärder (MLI). I sin redogörelse för oförutsägbarheten i PPT-bestämmelsen36 påpekar

*The OECD Observer, the Organization’s public magazine, also keeps readers up to date on key issues related to OECD work. 13. OECD BEPS (IN)ACTION 1 257 (the 2013 Report).3 BEPS is tax planning that shifts profits “in ways that erode the taxable base to locations where they are subject to a more favour-able tax treatment.”4 The report emphasizes the “pressing and current issue” of BEPS and the resulting “serious risk to tax revenues, tax sovereignty and 13 See EY Global Tax Alert, OECD releases report under BEPS Action 13 on Transfer Pricing Documentation and Country-by-Country Reporting, dated 23 September 2014. 14 See EY Global Tax Alert, OECD releases report under BEPS Action 15 on feasibility of developing multilateral instrument to amend bilateral tax treaties, dated 19 September 2014.